Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2022 (8) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2022 (8) TMI 196 - ITAT DELHIAddition on account of interest - excessive interest on the borrowings - CIT-A deleted the addition - HELD THAT:- AO on the basis of working given in the assessment order had concluded that assessee had charged lower interest on the amount advanced as compared to the higher interest paid on the amount borrowed. AO thereafter, worked out the interest that should have been charged by the assessee. When the matter was carried before CIT(A), CIT(A) after considering the submissions of the assessee had given a finding that the average rate of interest paid by the assessee was less than the average rate of interest earned by the assessee and thus assessee had not paid excessive interest on the borrowings. He has further given a finding that the addition made by AO was based on erroneous working. Before us, Revenue has not pointed any fallacy in the findings of CIT(A). In such a situation, we find no reason to interfere with the order of CIT(A). Thus the ground of Revenue is dismissed. Disallowance u/s 14A - grievance of the assessee in this ground is that AO had considered the investment in mutual funds while working out the disallowance under Rule 8D - HELD THAT:- On perusal of the investments schedule placed in the audited Balance Sheet reveals that assessee has stated investment in mutual funds and also stated the investment in equity shares of ICICI Advantages - In view of the aforesaid facts, we do not find any merit in the submissions of the Learned AR that the investments are in mutual funds and therefore, needs to be excluded. We, thus, dismiss the Ground of the cross objection of the assessee.
|